SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Advertisement, marketing and promotion (AMP) expenditure did not constitute an international transaction for transfer-pricing purposes, consistent with earlier orders concerning the assessee. Because an arm's length price adjustment presupposes an international transaction, no adjustment could be made for that expenditure. The deletion of the AMP adjustment was sustained, the Revenue's appeals were dismissed, and the assessee's cross-objections became infructuous.
Advertisement, marketing and promotion (AMP) expenditure did not constitute an international transaction for transfer-pricing purposes, consistent with earlier orders concerning the assessee. Because an arm's length price adjustment presupposes an international transaction, no adjustment could be made for that expenditure. The deletion of the AMP adjustment was sustained, the Revenue's appeals were dismissed, and the assessee's cross-objections became infructuous.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
